ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................... ii
ITEM 6 - SUPERVISION .............................................................................................................................. ii
DAVID A. HORVITZ, CFP® .................................................................................................................... iii
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ...................................................... iii
Professional Designations ................................................................................................................... iii
ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... iv
ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... iv
ITEM 6 - SUPERVISION ............................................................................................................................. iv
JAMES M. WHITING, CFP® ................................................................................................................... v
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ....................................................... v
Professional Designations .................................................................................................................... v
ITEM 3 - DISCIPLINARY INFORMATION .................................................................................................... vi
ITEM 5 - ADDITIONAL COMPENSATION ................................................................................................... vi
ITEM 6 - SUPERVISION ............................................................................................................................. vi
PAUL MATHESON ............................................................................................................................. vii
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ..................................................... vii
Cheviot Value Management Brochure Revised May 23, 2024 6
ITEM 3 - DISCIPLINARY INFORMATION ................................................................................................... vii
ITEM 5 - ADDITIONAL COMPENSATION .................................................................................................. vii
ITEM 6 - SUPERVISION ............................................................................................................................ vii
PRIVACY NOTICE ............................................................................................................................... A
Cheviot Value Management Brochure Revised May 23, 2024 7
Description of Advisory Firm
Cheviot Value Management, LLC (“CVM,” “we,” “our,” or “us”) is a privately owned limited liability
company headquartered in Beverly Hills, CA. Frederic G. Marks and Nancy J. Marks founded CVM in
1974. In 1985, the firm transitioned to investment management and became registered with the U.S.
Securities and Exchange Commission in 1985. David A. Horvitz and Darren C. Pollock assumed control of
the firm in January 2013 upon the Marks’ retirement.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty carries
with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and
confidence. It encompasses a
duty of care and a
duty of loyalty.
Duty of Care
The duty of care includes, among other things,
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of the client’s
objectives is a critical component of the duty of care. Providing suitable advice includes making a
reasonable inquiry into the client’s financial situation, investment experience, and financial goals and
then updating this information as necessary throughout the course of the relationship to reflect the
client’s changing objectives over time and adjusting the advice we provide to reflect any changed
circumstances.
When CVM has the responsibility to select broker-dealers to execute client trades in discretionary
accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most
favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s
services and so the determinative factor is not necessarily the lowest possible commission cost but
whether the transaction represents the best qualitative execution. Moreover, we periodically and
systematically evaluate the execution we receive on behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the
best interest of the client, taking into account the scope of the agreed relationship. This scope is
indicated by the duration and nature of the services as outlined in each client’s advisory arrangement
and extends to all personalized advice provided to clients.
Duty of Loyalty
CVM adheres to a duty of loyalty where we seek to serve the best interests of our clients and never
subordinate the interests of our clients to our own. Simply put, CVM cannot place its own interests
ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to
clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at
least expose through full and fair disclosure all conflicts of interest which might incline CVM, consciously
Cheviot Value Management Brochure Revised May 23, 2024 8
or unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to
be
full and fair, it should be sufficiently specific so that each client is able to understand the material fact or
conflict of interest and make an informed decision whether to provide consent. Consequently, we
provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they
can use the information within to decide whether or not to enter into an advisory relationship.
Advisory Services Offered
CVM offers the following services to advisory clients:
Investment Management Services
CVM provides continuous and regular investment supervisory services on a discretionary basis. Darren
C. Pollock, David A. Horvitz, and James M. Whiting have the ongoing responsibility to select investments
CVM purchases or sells in client accounts.
CVM will primarily utilize the following investment types when making purchases in client accounts:
1. Equity securities, including stocks and foreign securities listed on US exchanges (ADRs) or foreign
exchanges (ordinaries)
2. Fixed income securities, including corporate and government bonds
3. Municipal securities
4. Exchange traded funds (ETFs)
5. Money market funds and other cash equivalents
Depending on the client’s individual investment objectives and needs, many portfolios further include,
as CVM deems appropriate:
1. Securities with equity and debt characteristics, including convertible bonds, preferred stocks or
other preferred securities
2. Mutual funds*
3. Closed-end funds
4. Master limited partnerships (MLPs)
*Mutual funds are generally utilized only in special situations, including but not limited to seeking
diversification in smaller accounts or accessing certain securities in the fund’s underlying holdings that
would otherwise be difficult to obtain. CVM may also occasionally utilize additional types of investments
at our discretion. We describe the material investment risks for many of the securities that we utilize
under the heading Specific Security Risks in Item 8 below.
Limitations on Investments
In some circumstances, CVM’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
In the event CVM is managing assets within a retirement plan such as 401(k), 403(b), QRP or other
employer plan, CVM is limited to those investment providers and investment options chosen by the plan
Cheviot Value Management Brochure Revised May 23, 2024 9
administrator. Similarly, when we provide services to participants in an employer-sponsored plan, the
participant may be limited to investing in securities included in the plan’s investment options. Therefore,
CVM can only select investments to the client from among the available options and will not invest the
client’s account in other securities, even if there may be more suitable options elsewhere.
Mutual Fund Limitations
Generally, CVM limits mutual fund selections to no load funds or load-waived equivalents.
Limitation by Client
CVM may also limit advice based on certain client-imposed restrictions. For more information about the
restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in
this Item below.
Financial Planning Services
CVM provides complimentary financial planning services as part of our overall investment management
services at a client’s request or for a separate fee to non-investment management clients, as described
below. Clients receive a written financial plan providing the client with detailed analyses and
recommendations designed in an effort to help them achieve their stated financial goals and objectives.
In general, we seek to address all or part of the following areas in the financial plan:
• Goals and objectives
• Net worth
• Cash flow planning
• Tax planning review
• College funding
• Risk management and insurance planning
• Retirement planning
• Investment planning
• Estate planning
CVM gathers information through in-depth personal interviews and document requests. Information
gathered generally includes a client’s current financial status, future life goals, and attitudes towards
risk. Related documents supplied by the client are carefully reviewed by CVM, and a written report is
prepared. Should a client choose to implement the recommendations contained in the plan, CVM
suggests the client work closely with his/her attorney, accountant, insurance agent, mortgage broker,
and/or investment adviser. Implementation of financial plan recommendations is entirely at the client’s
discretion. Clients may choose but are not required to have CVM assist with financial plan
implementation, including investment management services. Fees for investment management and
stand-alone financial planning services are described below in Item 5 – Fees and Compensation. Clients
that choose to utilize CVM for financial plan implementation should keep us informed of any changes to
their financial situation so that we can determine if corresponding adjustments to the financial plan are
necessary.
Cheviot Value Management Brochure Revised May 23, 2024 10
Budget Coaching Services
CVM will support the client using a finance management software platform to assist the client
with creating a personalized budget that includes categorizing expenses, creating categories, and
planning for upcoming expenses. CVM’s support includes an initial consultation, budget construction
and software orientation session, and three follow-up budgeting sessions. Additional blocks of four
budgeting sessions are available for purchase as detailed under Item 5 – Fees and Compensation,
below.
Non-Managed Assets
At its discretion, CVM may offer securities trading activities for cash and securities in a client’s non-
managed account, acting as an intermediary between the client and the custodian of the non-managed
account. We do not generally provide investment advice regarding a client’s non-managed assets or
provide opinions as to the merits of any securities in non-managed accounts. We also do not make any
judgments as to the appropriateness of assumed risk or suitability of any non-managed investment
given the client’s situation. At our discretion, CVM may offer this service in consideration of the client’s
other accounts that we manage.
Tailored Services and Client Imposed Restrictions
CVM makes individual investment decisions for clients based on a financial review and plan to help
clients formulate realistic investment objectives. We then develop an investment policy in an effort to
achieve those objectives. It is the client’s responsibility to keep us informed of any changes to his/her
investment objectives.
In limited circumstances, clients may request restrictions on the account, such as when a client needs to
keep a minimum level of cash in the account or does not want us to buy or sell specific securities or
security types in the account. CVM reserves the right to not accept and/or terminate management of a
client’s account if we feel that the client-imposed restrictions would limit or prevent us from meeting or
maintaining our overall investment strategy for the client.
Wrap Fee Programs
We do not provide portfolio management services to a wrap fee program.
Assets Under Management
CVM manages client assets in discretionary accounts on a continuous and regular basis. As of January
29, 2024, CVM had $822,972,737 in assets under our management.